To amend the Internal Revenue Code of 1986 to provide for a right to an administrative appeal relating to adverse determinations of tax-exempt status of certain organizations.

[AI summary unavailable — showing source text] Amends the Internal Revenue Code to require the Secretary of the Treasury to prescribe regulations for allowing a tax-exempt organization to request an administrative appeal to the Internal Revenue Service (IRS) Office of Appeals of an adverse determination with respect to: (1) the initial or continuing qualification of such organization as tax-exempt, or (2) the initial or continuing classification of such organization as a private foundation or a private operating foundation.…